Website accessibility in Australia: what small businesses need to know

In Australia, the Disability Discrimination Act 1992 makes it unlawful to discriminate against people with disability when providing goods and services, and that includes services delivered through a website. The Act doesn’t set technical rules for websites. Instead, the Australian Human Rights Commission’s 2025 guidelines say organisations should, at a minimum, meet the Web Content Accessibility Guidelines (WCAG) 2.2 at Level AA. That is the practical benchmark for a small business website.

This guide explains what that means in plain terms, the problems that turn up most often on small business sites, and a self-check you can run in about an hour. It’s general information, not legal advice. If you have a specific complaint or concern, get independent legal advice.

The short legal answer: the DDA, the AHRC and WCAG

Three things fit together here.

• The law. The Disability Discrimination Act 1992 (the DDA) makes disability discrimination unlawful in areas of public life, including the provision of goods, services and facilities, whether they’re paid for or free.
• The regulator’s guidance. The Australian Human Rights Commission (AHRC) handles complaints under the DDA. In April 2025 it published Guidelines on equal access to digital goods and services. The Commission says the guidelines are not legally binding, but meeting them will help organisations meet their obligations, and they are the minimum to aim for.
• The technical standard. The guidelines say organisations should conform with WCAG 2.2 at a minimum Level AA. WCAG is published by the W3C, the international body that sets web standards.

This isn’t new territory. The AHRC’s guidance points to a 2000 decision, Maguire v Sydney Organising Committee for the Olympic Games, where the Commission found that information on a website is a service under the DDA and that an inaccessible website was discrimination against a blind man.

Who it applies to (and why small businesses should care anyway)

The DDA applies to anyone providing goods or services to the public. It doesn’t carve out small businesses. A clinic with an online booking form, a tradie with a quote request page and a retailer with a shop all provide services through their websites.

For most small businesses the realistic risk is a complaint from someone who couldn’t use the site, which goes to the AHRC. Even so, the better reasons to care are commercial:

• People with disability, and older people with declining eyesight or dexterity, are customers. If they can’t use your booking form, they book somewhere else.
• Many accessibility fixes also make a site easier for everyone: clearer headings, readable text, forms that explain errors, and buttons big enough to tap on a phone.
• Clear headings and descriptive links also make your pages easier for search engines to understand.

If your site gets visits but few enquiries, accessibility problems can be part of the reason. Our guide on why a website gets visitors but no enquiries covers the other common causes.

The problems we see most on small business sites

WCAG has dozens of success criteria, but small business sites tend to fail on the same handful. In owner terms:

You can read every criterion in the W3C’s WCAG overview. Level AA includes everything at Level A as well.

A 10-point self-check you can do in an hour

The W3C publishes Easy Checks, a first review anyone can do. The list below is based on it. It won’t tell you that your site conforms, and the W3C says a page can pass these checks and still have serious barriers. It will tell you where the obvious problems are.

1. Page titles. Each page’s browser tab shows a title that says what the page is, not just your business name.
2. Keyboard only. Put the mouse away and use Tab, Shift+Tab and Enter. Can you reach the menu, every link and every form field, and submit the form?
3. Visible focus. While tabbing, can you always see where you are?
4. Images. Do meaningful images have a short text description? Decorative ones should be marked as decorative.
5. Headings. Does each page have one main heading, with subheadings in a logical order?
6. Contrast. Is all text clearly readable, including text on buttons and over images? Free contrast checkers will give you a ratio to compare with 4.5:1.
7. Zoom. Zoom the browser to 200%. Does everything still fit and work?
8. Link text. Do links say where they go, such as “View our fees” rather than “click here”?
9. Forms. Does every field have a visible label? Submit a form with mistakes. Does it tell you clearly what went wrong and where?
10. Video and audio. Do videos have captions, and do any videos or carousels play automatically without a way to stop them?

Write down every failure with the page address. That list is your starting brief.

Forms, booking widgets and PDFs: the usual weak spots

Forms

Placeholder text inside a field that disappears when you start typing isn’t a label. Error messages that only turn a box red don’t tell a screen reader user anything. CAPTCHA puzzles can block people entirely. Fixing your enquiry and contact forms is usually the most valuable single change, because they’re where customers actually reach you.

Third-party booking and payment widgets

Many sites embed a booking calendar, chat tool or payment form from another company. The AHRC’s guidelines say that using a vendor doesn’t move your equal access obligation onto them. Test the widget with a keyboard. If it fails, ask the vendor what they’re doing about it, and consider that when you next review your tools.

PDFs

Menus, price lists, forms and brochures are often uploaded as PDFs. The AHRC’s guidelines note that PDFs can’t be made fully accessible, especially on mobile devices, and that where PDFs are provided they should meet the accessible PDF standard. The simpler fix is to put the important information on a normal web page and keep the PDF as an optional download.

Why an accessibility overlay is not a fix

An overlay is a script added to a website, usually showing a small accessibility icon, that promises to fix problems automatically or let visitors adjust the page. They are heavily marketed to small businesses as a quick route to compliance.

The evidence points the other way. In its 2025 guidelines, the AHRC refers to plug-in overlays that “allegedly improve” accessibility and says AI applications are not yet reliable in most situations. In the United States, the Federal Trade Commission in 2025 finalised an order against one overlay vendor over claims that its tool could make any website WCAG compliant.

The underlying problem is that an overlay sits on top of the code. It can’t reliably fix a form with no labels, a menu that can’t be reached by keyboard or a video without captions.

Building it in when you redesign

Accessibility is much cheaper to build in than to retrofit. If you’re planning a new site, put it in the brief:

• State that the site should meet WCAG 2.2 Level AA, and ask how the agency will test it.
• Choose colours and fonts with contrast in mind before the design is signed off.
• Ask for keyboard and screen reader testing of the menu, forms and any booking or payment step.
• Ask how third-party tools you plan to embed have been checked.
• Get training on writing image descriptions, headings and link text, so new content stays accessible.
• Add a contact option for people who have trouble using the site.

When you’re comparing agencies, this belongs on your list of questions to ask a web designer.

Where to start

1. Run the 10-point self-check on your home page, your main service page and your contact or booking page.
2. Fix your enquiry and booking forms first, since that’s where customers reach you.
3. Replace important PDFs with web pages.
4. Remove any overlay you’re relying on for compliance, and fix the underlying issues instead.
5. Read the AHRC’s guidelines, and add WCAG 2.2 Level AA to the brief for your next redesign.

If your self-check turns up more than a few problems, a rebuild is often simpler than patching. Our website design and build work includes accessibility testing from the start, and we’re happy to look at your list with you.